The EPA registered its assessment (pdf) of the plan in the published draft’s comment section, which closed on Monday with 12,000 contributors. Although the agency had kind words for the effort and approved of the general framework, it thought the environmental impact report, or DEIS, was deficient in significant ways and the plan was based on outdated assumptions and data.

The 10,000-page draft was five years in the making and sets the stage for California’s push to reach its 2050 goal of energy emissions 80% below 1990 levels. It is a joint production of agencies within the U.S. Department of the Interior and California’s Natural Resources Agency.

The EPA noted that at the core of the report was a calculation from July 2012 that the state would need 20,000 megawatts of power generated by large-scale wind, solar and geothermal projects in the desert and inland valleys, spread across 22.5 million acres in Imperial, Inyo, Kern, Los Angeles, Riverside, San Bernardino and San Diego counties.

However, “significant market and policy developments affecting the renewable energy industry, since the aforementioned 2012 revision, warrant a re-evaluation of the 20,000 MW planning objective,” the EPA said.

In other words, the price of solar is dropping as more homes and business throw units on rooftops, and we are finding new ways to store and transmit the accumulated energy. Do we really need all of these mega-developments that everyone agrees will hurt the environment?

The report, itself, acknowledges, “The development of large-scale renewable projects in Development Focus Areas would also impose dramatic visual changes to high-value recreational areas. Over 40 percent of the Development Focus Areas for any of the action alternatives are within 5 miles of Legally and Legislatively Protected Areas.”

That includes Death Valley, Joshua Tree National Park and Mojave National Preserve.

The new plan is meant to replace the haphazard development that burst across the desert after the federal government made billions of dollars of stimulus money available shortly after President Obama was elected.

The EPA gave the DEIS an official rating of EC-2—“environmental concerns” that need to be addressed—“EPA would like to work with the lead agency”—and insufficient “information for EPA to fully assess environmental impacts that should be avoided.”

The EPA warned about lack of compliance with the Clean Water Act and the Clean Air Act, lack of attention to recent spikes in bird deaths at wind facilities, and the need to update with the latest guidelines on climate change from the Council on Environmental Quality.